[arin-ppml] ARIN-2015-3:(remove 30-day...) Staff interpretation needed

Tue May 10 11:48:11 EDT 2016

John,

Thank you for the lengthy description.  I'm not sure I understand what your
estimate means so I will attempt to restate them for clarity.

It sounds like in 50% - 75% of the requests that are approved
have historical utilization is sufficient to provide approval.  Example A &
C.

It sounds like in 25% - 50% of the requests that are approved
have historical utilization is not sufficient to provide approval.  Example
B.

It sounds like you did not provide information on how often a request
justified on a future projection is approved only in the amount justified
by historical utilization Example C, or is altogether denied or abandoned.

Do these numbers include both end-user and ISP requests?
Could you provide a similar estimate broken down between end-user and ISP
requests?

Do both ISP requests and end-user requests have the same percentage
of requests approved being more heavily weighted by historical utilization
trend information?

 Or do end-user requests have a higher percentage of approvals being
 more heavily weighted by historical utilization trend information?

Or do ISP requests have a higher percentage of approvals being
 more heavily weighted by historical utilization trend information?

Thanks,

__Jason

On Sat, May 7, 2016 at 7:15 AM, John Curran <jcurran at arin.net> wrote:

> On Apr 25, 2016, at 12:47 PM, Jason Schiller <jschiller at google.com>
> wrote:
>
> ...
> I suspect the 30 days part does (to some extent) regulate outrageously
> large claims, as this is a real short term verifiable commitment.  Without
> a possibility of a 30 day check you simply fall back to an officer
> attestation of a two year projected need claim.
>
> I am trying to figure out what is the likely impact of only requiring a
> two year projected need claim.  So my questions are regarding to what level
> of push back ARIN provides against two year projected need in general, and
> will that be sufficient to prevent outlandishly large claims.
>
> Maybe another way to get at this is to compare end user transfer stats to
> ISP transfer stats.
> - what percentage of ISP specified transfers are justified by past growth?
>  by a two year projection?
> - what percentage of end user specified transfers are justified by past
> growth?  by a two year projection?
> - what is the average size of ISP specified transfers that are justified
> by past growth?  by a two year projection?
> - what is the average size of end user specified transfers that are
> justified by past growth?  by a two year projection?
> - do we see a greater gap between average ISP size between specified
> transfers that are justified by past growth vs. by a two year projection?
> - do we see a greater percentage of ISP transfers justified by a 2 year
> projection than end users?
>
>
> Jason -
>
>     While we dp collect statistics on the number of requests and outcomes,
> we do
>     not have the instrumentation of the needs-assessment process that
> would be
>     necessary to produce the type of statistics you request.  It is also
> not clear that
>     such instrumentation would allow us to provide an exact percentage of
> requests
>     that are approved based on past growth vs. projections because ARIN
> takes
>     both factors into account when evaluating operational need.
>
>     In order to provide some insight into how the needs-assessment process
> operates
>     with respect to past growth versus projection, we’ve provided several
> examples on
>     how the needs-assessment process would unfold for various 8.3
> specified transfer
>     scenarios detailed below.
>
>     When an existing ARIN account, ISP or End-User, requests an 8.3
> Recipient
>     Transfer, ARIN will look at their historical utilization and determine
> the organizations
>     average 24-month usage trend.  We will compare that to what they are
> currently
>     requesting to have transferred and determine if that amount
> aligns with their prior
>     utilization trend. If it does align directly, then we consider that
> the justification for
>     their 24-month stated need, but often we have to also give some
> consideration to
>     the information they provide regarding future plans and potential
> impact on growth
>     rate.
>
> === Example A
> An existing ARIN Organization requests a /16 transfer via 8.3 transfer
> process.
> They previously received the following IPv4 address space:
> /17 in December 2015
> /17 in October 2015
> /18 in July 2015
> /19 in June 2015
> /20 in May 2015
> /20 in February 2015
>
> In this example, ARIN would request 24-month projections AND utilization
> information from the organization. We would verify they have utilized
> their previously received IPv4 blocks in accordance with policy and
> determine their utilization trend. In this example, the organization has
> fully utilized their previous allocations and we note their historical
> utilization of 384 /24s over the past 18 months. Even though we are also
> taking their future plans into consideration, their prior utilization trend
> is heavily weighted in justifying the newly requested /16 and they are
> approved. Their prior 24 months of utilization exceeds what they are
> requesting for the next 24 months.
>
> === Example B
> An existing ARIN Organization requests a /16 transfer via 8.3 transfer
> process.
> They previously received the following IPv4 address space:
> /19 in December 2015
> /20 in October 2015
> /21 in July 2015
> /22 in June 2015
> /23 in May 2015
>
> In this example, ARIN would again request 24-month projections AND
> utilization information from the organization.  We would verify they
> have utilized their previously received IPv4 blocks in accordance with
> policy and determine their utilization trend.  In this example, the
> organization has fully utilized their previous allocations and we note
> their historical utilization trend of 62 /24s over the past 11 months.
> Their prior utilization suggests a utilization trend of 136 /24s over a
> 24-month period (62 / 11 * 24mos = 135.3 or 136).  The organization’s
> 24-month utilization trend does not meet or exceed the amount of IPv4
> address space they are requesting for the next 24-month period, so the
> information they provide regarding their future plans/need is more heavily
> weighted by ARIN staff. The information provided regarding future need
> paired with their utilization trend allows for an approval for the
> requested size (/16).
>
> === Example C
> An existing ARIN Organization requests a /16 transfer via 8.3 transfer
> process.
>
> Without providing the further background details, the requesting
> organization in this example has utilized their previously received blocks
> in accordance with policy and has a 24-month utilization trend of 65 /24s.
> The organization’s 24-month utilization trend does not meet or exceed the
> amount of IPv4 address space they are requesting for the next 24-month
> period, so the information they provide regarding their future plans/need
> is more heavily weighted by ARIN staff. The future need projections only
> slightly increase expected future utilization over their prior utilization
> trend and a need for 100 /24s is determined for the next 24-month period.
> Unfortunately, the information provided regarding future need paired with
> their utilization trend does not allow for the approval of the requested
> /16, and a /17 (closest prefix size above their demonstrated need amount)
> is approved instead.
> ===
>
>    Similarly, if a new organization comes to ARIN for an 8.3 Recipient
> Transfer we
>    would base their approval on any provider assigned space they are
> currently using
>    and their projections. We would do this similar to the examples noted
> above.
>
>    It is important to note that if a new organization comes to ARIN and
> isn't using any
>    provider assigned space, we are only be able to base their approval
> amounts based
>    on their projections.
>
>    When we ask organization for their forward projections, we also ask
> them to provide
>    details to show how they've arrived at their projections. We take into
> account factors
>    such as new networks, locations, products, services they plan on
> offering (and this
>    includes consideration of anticipated address utilization within the
> first 30 days for
>    end-users.)
>
>    Given we take all of these factors into account (and noting that we
> don’t precisely track if
>    they qualified more heavily on historical usage vs. projections), we
> would estimate between
>    50-75% of the approval decisions made are more heavily weighted by
> historical utilization
>    trend information. It is important to note that the
> historical utilization trend information often
>    allows for an approval size equal to or greater than what is requested
> by most organizations.
>
> While this is not the level of detail that you desire, I hope it provides
> some useful insight
> into the role of the future projections in the needs-assessment process.
>
> Best wishes on your policy development efforts!
> /John
>
> John Curran
> President and CEO
> ARIN
>
>
>
>
>

-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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